New FEMA Regs. - This could be huge.

I got this little goodie in an email this morning.  If you have been doing CLOMR-Fs or CLOMRs the cost to your client may have just gone up by a factor of 10 or more and the regulatory time period necessary to do the work may have just increased by several years.

EFFECTIVE OCTOBER 1, 2010 FEMA will institute a new mandatory requirement for Conditional Letters of Map Revision (CLOMR).

All CLOMR-Fs and CLOMRs received on or after October 1, 2010 will be required to show compliance with the Endangered Species Act prior to issuance of the CLOMR-F or CLOMR.

Please see the attached memorandum for more information.

I don't claim to know all the details as I have not been doing this sort of work.  If you do do this sort of work, it's time to figure out how this will affect you and your clients.

Larry P

Seems strange to be tying this into a CLOMR.

How do they deal with sites that have "adverse affect" but don't need a CLOMR? Isn't there an independent administrative process already in place?

Why tie the two together?

LOL...

I do not perform LOMA's...not enough pay. I am in business to make money and with FEMA that is not an option, now it seems more out of reach.

I do not do LOMA's but I have under the Endanagered Species Act, an Incidental Take Permit. One of my corporations has fishery permits from the National Marine Fishery Services (NMFS). Since NMFS believes with the fishery permits I have that I may be "interacting" with endangered species I go on a list. Each year everyone on the list gets an Incidental Take Permit automatically for free.

Are not surveyors on the Endangered Species list?